The SAGEClinician Podcast with Barbara C Phillips, NP

Billing Incident-To? Here are the Rules - NPBS26

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The SAGEClinician Podcast with Barbara C Phillips, NP

Barbara C Phillips, NP, FAANP

Description: Smart, Astute, Gutsy and Enlightened Clinicians

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Billing Incident-To? Here are the Rules - NPBS26

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Does the idea of Incident To billing leave you perplexed? Are you working with individuals who insist that all your visited be billed out as incident-to? Well, this is what we are going to talk about today on the NPBusiness Show podcast.

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Incident-To Billing

Incident-to billing can be confusing. Many NPs find their employers wanting to do a lot of incident-to billing. The problem is it can potentially result in fraud charges if the rules are not followed.

Define (as per CMS): “Incident to” services are defined as those services that are furnished incident to physician professional services in the physician’s office (whether located in a separate office suite or within an institution) or in a patient’s home. These services are billed as Part B services to your carrier as if you personally provided them, and are paid under the physician fee schedule.

Allowable Discount: 15% to NPs and PAs. For example, if MD is allowed $100, NPs/PAs are allowed $85.

Rules:
  • First of all the visit takes place in the office.
  • The physician must perform the initial service and continue to be actively involved in the course of treatment.
  • The NP or PA sees the patient in follow-up for the identified problem and follows the plan of care.
  • The physician MUST be in the office suite at the time the visit takes place, not necessarily in the exam room, but in the office incase “direct” supervision is required.
  • The documentation needs to reflect the essential requirements for an incident to services.
  • The NP or PA must be an employee or what medicare refers to as a “leased employee” or an “independent contractor” that is paid for by the physician and practice.
Other Note: “Incident to” services are also relevant to services supervised by certain non-physician practitioners such as physician assistants, nurse practitioners, clinical nurse specialists, nurse midwives, or clinical psychologists. These services are subject to the same requirements as physician-supervised services. Remember that “incident services” supervised by non-physician practitioners are reimbursed at 85 percent of the physician fee schedule. For clarity’s sake, this article will refer to “physician” services as inclusive of non-physician practitioners.   CMS Documentation: http://go.cms.gov/1Y3xJ8H (shortened) Your Turn

What's your experience with incident-to billing?

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